UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

 FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 

Regulatory Docket No. _______________ 

IN THE MATTER OF THE PETITION FOR EXEMPTION OF:

HiFlite Productions LLC

FOR AN EXEMPTION SEEKING RELIEF FROM THE REQUIREMENTS OF

 TITLE 14 OF THE CODE OF FEDERAL REGULATIONS

SECTIONS 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), AND 91.417(a) & (b) CONCERNING COMMERCIAL OPERATION OF DJI Inspire 1UNMANNED AIRCRAFT SYSTEMS 

PURSUANT TO SECTION 333 OF 

THE FAA MODERNIZATION AND REFORM ACT OF 2012

 (PUBLIC LAW 112-95) 

___________________________________________________________________________

Submitted on August 12, 2015

Ethan A Gulnac

HiFlite Productions LLC

2385 Puu Mala Place, Kihei HI 96753

Tel: (808) 874-3512 

Email: hifliteproductions@gmail.com 
TABLE OF CONTENTS 

GLOSSARY OF ABBREVIATIONS................................................................3 

SUMMARY.............................................................................................4 

INTRODUCTION AND INTERESTS OF PETITIONER.......................................4 

BACKGROUND.......................................................................................4 

BASIS FOR PETITION...............................................................................5 

NAME AND ADDRESS OF PETITIONER...............................................7 

SPECIFIC SECTIONS OF 14 C.F.R. FROM WHICH HIFLITE 

 PRODUCTIONS SEEKS EXEMPTION....................................................8 

EXTENT OF RELIEF HIFLITE PRODUCTIONS LLC SEEKS AND 

 THE REASON HIFLITE PRODUCTIONS LLC SEEKS THE RELIEF..............11 

REASONS WHY GRANTING HIFLITE PRODUCTIONS LLC’ REQUEST

 WOULD BE IN THE PUBLIC INTEREST...............................................15 

THE REASONS WHY GRANTING THE EXEMPTION WOULD NOT

 ADVERSELY AFFECT SAFETY..........................................................19 

SUMMARY THAT CAN BE PUBLISHED IN THE FEDERAL REGISTER.......34 

ANY ADDITIONAL INFORMATION, VIEWS, OR ARGUMENTS 

 AVAILABLE TO SUPPORT NARRATE STUDIOS LLC’S REQUEST.............34 

CONCLUSION........................................................................................35 
GLOSSARY OF ABBREVIATIONS

AGL

AOI

ATC

ATO

AV

CFR

COA

FAA

FAR

GCS

GPS

LOL

NAS 

NOTAM

PIC

Section 333

SO

SOP

UA

UAS

VFR

VLOS

VMC

VTOL 

Above Ground Level

Area of Interest

Air Traffic Control

Air Traffic Organization

Aerial Vehicle 

Code of Federal Regulations

Certificate of Authorization

Federal Aviation Administration

Federal Aviation Regulation

Ground Control Station 

Global Positioning System

Loss of Link

National Airspace System

Notice to Airman 

Pilot In Command

FAA Modernization and Reform Act of 2012 (FMRA) Section 333 

Safety Observer

Standard Operating Procedures

Unmanned Aircraft

Unmanned Aircraft System

Visual Flight Rules

Visual Line of Site

Visual Meteorological Conditions

Vertical Takeoff and Landing 
SUMMARY 

Ethan A. Gulnac seeks exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 

91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b), 

to operate an Unmanned Aircraft System pursuant to Section 333 of the FAA Modernization 

and Reform Act of 2012 (FMRA). This exemption will permit HiFlite Productions LLC to operate an Unmanned Aircraft System (UAS) for the commercial purpose of conducting aerial 

video and photography of construction sites, real estate, special events, film sets, and landscape 

over certain areas of the United States. 

INTRODUCTION AND INTERESTS OF THE PETITIONER 

HiFlite Productions LLC strives to provide its clients with the highest quality digital content for 

use in their commercial, personal, and non-profit multimedia projects. HiFlite Productions LLC 

has over 10 years recreational/hobby experience in all aspects of aerial video and photography. 

The objective of HiFlite Productions LLC aerial video and photography operations is to provide high quality imaging for a variety of commercial, public, and residential uses, specifically 

targeting: 

• Aerial event photography

• Real Estate Marketing

• Aerial event filming 

• Film production 

• Aerial location scouting and safety inspection 

• Increase public knowledge of UAS and promote safe UAS operations. 
BACKGROUND 

Unmanned Aircraft Systems: DJI Inspire 1 

HiFlite Productions LLC seeks an exemption to operate DJI Inspire 1 for compensation 

or hire within the NAS. The DJI Inspire 1 is a vertical takeoff and landing (VTOL) Unmanned Aircraft (UA) with a Ground Control Station (GCS) utilizing electronic tablet or 

smart phone systems. The DJI Inspire 1 has a maximum gross weight of approximately 

4 pounds and a maximum speed of approximately 40 knots. The DJI Inspire 1 is 

equipped with four main rotors; driven by Lithium Polymer battery powered electric 

motors. 

UAV Details

Make: DJI Innovations

Model : Inspire 1

Type: VTOL - Quadcopter Rotorcraft

Maximum Weight: 4 pounds

Maximum Payload: 2 Pounds

The DJI Inspire 1 UA that will be operated by HiFlite Productions LLC will be registered in 

accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Part 47, Aircraft 

Registration, and marked in accordance with 14 C.F.R. Part 45, Identification and Registration 

Marking. 

BASIS FOR PETITION 

Petitioner, HiFlite Productions LLC, pursuant to the provisions of the Federal Aviation Regulations (14 C.F.R. § 11.61) and the FAA Modernization and Reform Act of 2012 (FMRA), Section 333, Special Rules for Certain Unmanned Aircraft Systems, hereby petitions the Administrator to commercially operate the DJI Inspire 1 in the National Airspace System (NAS), and 

for an exemption from the requirements of 14 C.F.R §§ 61.113(a) & (b), 91.7(a), 91.121, 

91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 
In consideration of the speed, weight, size, and limited operating area associated with the unmanned aircraft and its operation, HiFlite Productions LLC operation of DJI Inspire 1 meets the 

conditions of FMRA Section 333 and therefore, will not require an airworthiness certificate in 

accordance with 14 C.F.R. Part 21, Subpart H. 

Accordingly, HiFlite Productions LLC requests relief from Sections 91.405(a), 91.407(a)(1), 

91.409(a)(1) & (a)(2), and 91.417(a) & (b), as these sections set forth requirements for maintenance that only apply to aircraft with an airworthiness certificate. 

HiFlite Productions LLC submits that the requested relief is proper since an equivalent level of 

safety will be ensured. HiFlite Productions LLC will use experienced personnel or technicians 

to perform maintenance, alterations, or preventive maintenance on the UAS using the methods, 

techniques, and practices prescribed in the operating documents (i.e., Monthly Maintenance 

Log, and DJI Inspire 1 Instruction Manual). Furthermore, HiFlite Productions LLC will document and maintain all maintenance records for the DJI Inspire 1. 

Relief from certain requirements of Section 61.113(a) and (b), entitled Private pilot privileges 

and limitations: Pilot in command, is requested by HiFlite Productions LLC to the extent necessary to allow a Pilot in Command (PIC) holding a private pilot or higher level certificate, as 

well as an airman medical certificate, and who has demonstrated, by meeting minimum flighthour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a 

manner consistent with this exemption, including evasive and emergency maneuvers and maintaining appropriate distances from people, vessels, vehicles and structures. 

HiFlite Productions LLC seeks relief from Section 91.7(a), entitled Civil aircraft airworthiness, 

because the DJI Inspire 1 does not require an airworthiness certificate in accordance with 14 

C.F.R. Part 21, Subpart H. As such, HiFlite Productions LLC submits that it will ensure that the 

DJI Inspire 1 are in an airworthy condition, prior to every flight, by determining that the UA are 

in compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 

1Instruction Manual), and that the aircraft are in a condition for safe flight. 

HiFlite Productions LLC also seeks an exemption from the requirements of Section 91.121, entitled Altimeter Settings, as the DJI Inspire 1 will not have a typical barometric altimeter onboard. However, altitude information of the DJI Inspire 1 will be provided to the PIC via Global Positioning System (GPS) equipment and radio communications telemetry data link, which 

downlinks from the UA to the GCS for active monitoring of the flight path. This altitude information, combined with HiFlite Productions LLC’s operation of the DJI Inspire 1 within visual 

line of sight, at or below 500 feet AGL, will ensure a level of safety equivalent to Section 

91.121. 
Additionally, HiFlite Productions LLC seeks an exemption from the requirements of Section 

91.151(b), entitled Fuel requirements for flight in VFR conditions. HiFlite Productions LLC 

submits that safety will not be affected by operation of the DJI Inspire 1 during daylight hours 

in visual meteorological conditions (VMC) under visual flight rules (VFR), with enough battery power to fly for a total duration of approximately 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

In accordance with 14 C.F.R. § 11.81, HiFlite Productions LLC provides the following information in support of its petition for exemption:

A. Name And Address Of The Petitioner.

The name and address of the Petitioner and point of contact is: 

Ethan Gulnac

HiFlite Productions LLC

2385 Puu Mala Place Kihei, HI 96753

Tel: (808) 874-3512

Email: hifliteproductions@gmail.com 

B. The Specific Sections Of 14 C.F.R. From Which HiFlite Productions LLC Seeks Exemption. 1. HiFlite Productions LLC Seeks Exemption From The Requirements Of Section 61.113(a) And (b). 

Section 61.113, entitled Private pilot privileges and limitations: Pilot in command, subsections 

(a) and (b) prescribe the following, in relevant part: 

(a) No person who holds a private pilot certificate may act as a pilot in command (PIC) of an 

aircraft that is carrying passengers or property for compensation or hire; nor may that person, 

for compensation or hire, act as PIC of an aircraft. 

(b) A private pilot may, for compensation or hire, act as PIC of an aircraft in connection with 

any business or employment if— 

(1) The flight is only incidental to that business or employment; and

(2) The aircraft does not carry passengers or property for compensation or hire. 
2. HiFlite Productions LLC Seeks Exemption From The Requirements Of Section 91.7(a). 

Section 91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No 

person may operate a civil aircraft unless it is in an airworthy condition. 

3. HiFlite Productions LLC Exemption From The Requirements Of Section 91.121. 

Section 91.121, entitled Altimeter settings, subsection (a), states the following, in part: (a) Each 

person operating an aircraft shall maintain the cruising altitude or flight level of that aircraft, as 

the case may be, by reference to an altimeter that is set, when operating-- 

(1) Below 18,000 feet MSL, to-- 

(i) The current reported altimeter setting of a station along the route and within 100 nautical 

miles of the aircraft; 

(ii) If there is no station within the area prescribed in paragraph (a)(1)(i) of this section, the current reported altimeter setting of an appropriate available station; or 

(iii) In the case of an aircraft not equipped with a radio, the elevation of the departure airport or 

an appropriate altimeter setting available before departure. 

4. HiFlite Productions LLC Exemption From The Requirements Of Section 91.151(b). 

Section 91.151, entitled Fuel requirements for flight in VFR conditions, subsection (b), states 

the following: (b) No person may begin a flight in a rotorcraft under VFR conditions unless 

(considering wind and forecast weather conditions) there is enough fuel to fly to the first point 

of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes. 

5. HiFlite Productions LLC Exemption From The Requirement Of Section 91.405(a). 

Section 91.405, entitled Maintenance required, subsection (a), states the following: 

Each owner or operator of an aircraft— 

(a) Shall have that aircraft inspected as prescribed in subpart E of this part and shall between 

required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter[.] 
6. HiFlite Productions LLC From The Requirements Of Section 91.407(a)(1) Section 

91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(1), states the following: 

(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless-- 

(1) It has been approved for return to service by a person authorized under § 43.7 of this chapter. 

7. HiFlite Productions LLC Seeks Exemption From The Requirements Of Sections 

91.409(a)(1) And 91.409(a)(2). 

Section 91.409, entitled Inspections, subsection (a), states the following:

(a) Except as provided in paragraph (c) of this section, no person may operate an 

aircraft unless, within the preceding 12 calendar months, it has had -- 

(1) An annual inspection in accordance with part 43 of this chapter and has been approved for 

return to service by a person authorized by § 43.7 of this chapter; or 

(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of 

this chapter. 

8. HiFlite Productions LLC Exemption From The Requirements Of Sections 91.417(a) 

And 91.417(b). 

Section 91.417, entitled Maintenance records, subsections (a) and (b), state the following: 

(a) Except for work performed in accordance with §§ 91.411 and 91.413, each registered owner 

or operator shall keep the following records for the periods specified in paragraph (b) of this 

section: 

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-

hour, annual, progressive, and other required or approved inspections, as appropriate, for each 

aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. 

The records must include-- 

(i) A description (or reference to data acceptable to the Administrator) of the work performed; 

and 

(ii) The date of completion of the work performed; and 

(iii) The signature, and certificate number of the person approving the aircraft for return to service. 
(2) Records containing the following information: 

(i) The total time in service of the airframe, each engine, each propeller, and each rotor. 

(ii) The current status of life-limited parts of each airframe, engine, propeller, rotor, and appliance. 

(iii) The time since last overhaul of all items installed on the aircraft which are required to be 

overhauled on a specified time basis. 

(iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. 

(v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If 

the AD or safety directive involves recurring action, the time and date when the next action is 

required. 

(vi) Copies of the forms prescribed by § 43.9(d) of this chapter for each major alteration to the 

airframe and currently installed engines, rotors, propellers, and appliances. 

(b) The owner or operator shall retain the following records for the periods prescribed: 

(1) The records specified in paragraph (a)(1) of this section shall be retained until the work is 

repeated or superseded by other work or for 1 year after the work is performed. 

(2) The records specified in paragraph (a)(2) of this section shall be retained and transferred 

with the aircraft at the time the aircraft is sold. 

(3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter 

shall be retained until the defects are repaired and the aircraft is approved for return to service. 

C. The Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions LLC Seeks The Relief. 

1. Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions 

LLC Seeks Relief From Section 61.113(a) And (b). 

Relief from Section 61.113(a) and (b) entitled Private pilot privileges and limitations: Pilot in 

command, is requested to the extent necessary to allow a PIC holding a private pilot or higher 

level certificate, as well as a current and valid airman medical certificate, and who has met certain flight-hour and currency requirements, to conduct the proposed UAS flight operations for 

compensation or hire. 
This relief is requested since the limitations set forth in Section 61.113(a) and (b) state that a 

private pilot may, for compensation or hire, act as PIC of an aircraft in connection with any 

business or employment if: (1) The flight is only incidental to that business or employment; and 

(2) The aircraft does not carry passengers or property for compensation or hire. 

As set forth more fully below, HiFlite Productions LLC submits that an equivalent level of 

safety will be maintained because no PIC will be allowed to operate the DJI Inspire 1 unless 

that PIC has met certain flight-hour and currency requirements, demonstrating that the PIC is 

able to safely operate either the DJI Inspire 1 in a manner consistent with the operations specifications as described in this exemption, including evasive and emergency maneuvers, as well 

as maintaining appropriate distances from people, vessels, vehicles and structures. 

Further, HiFlite Productions LLC submits that all flights of the DJI Inspire 1, conducted by the 

PIC pursuant to the grant of this Petition: (1) will be incidental to HiFlite Productions LLC 

business; and (2) will not carry passengers or property for compensation or hire. 

2. Extent Of Relief HiFlite Productions LLC Seeks And The HiFlite Productions LLC 

Seeks Relief From Section 91.7(a). 

Relief from Section 91.7(a) entitled Civil aircraft airworthiness, is requested to the extent required to allow HiFlite Productions LLC to determine that the DJI Inspire 1 are in airworthy 

condition prior to every flight by ensuring that the UA is in compliance with the operating documents (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Inspire 1Instruction Manual). 

HiFlite Productions LLC seeks the requested relief because the DJI Inspire 1 do not require an 

airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. Therefore, HiFlite 

Productions LLC will ensure that the DJI Inspire 1 are in airworthy condition based upon its 

compliance with the operating documents (i.e., Monthly Maintenance Log, and DJI Inspire 

1Instruction Manual) prior to every flight, and further, determine that the aircraft are in condition for safe flight, as stated in the conditions and limitations below. 

3. Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions 

LLC Seeks Relief From Section 91.121. 

Relief from Section 91.121, entitled Altimeter settings, may be required to allow flight operations of the DJI Inspire 1, which utilize a barometric pressure sensor, GPS equipment, and a 

radio communications telemetry data link to downlink altitude information from the UA to the 

PIC at the ground control station (GCS). Since the FAA requires that any altitude information 

concerning UAS operations be reported to air traffic control (ATC) in feet above ground level 

(AGL), HiFlite Productions LLC seeks the requested relief because the DJI Inspire 1’s altimeter may be set on the ground to zero feet AGL, rather than the local barometric pressure or field 

altitude, before each flight. 
Considering the limited altitude of the proposed operations, relief from 14 CFR 91.121 is 

sought to the extent necessary to comply with the applicable conditions and limitations stated 

below. As more fully set forth herein, an equivalent level of safety will be maintained since the 

DJI Inspire 1 are equipped with a barometric pressure sensor and GPS equipment, which automatically ensures that a ground level pressure setting will be established prior to each flight, 

and provides the PIC with altitude information of the UA on the heads-up display of the GCS. 

4. Extent Of Relief HiFlite Productions LLC Seeks And The HiFlite Productions LLC Relief From Section 91.151(b). 

Relief from Section 91.151(b) entitled Fuel requirements for flight in VFR conditions, is requested to the extent required to allow flights of the battery powered DJI Inspire 1 during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), for a 

total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. HiFlite Productions LLC seeks the requested 

relief because without an exemption from Section 91.151(b), the flight time duration of the battery powered DJI Inspire 1 will severely constrain the practicality of any aerial video or still 

photo flight operations that HiFlite Productions LLC proposes to conduct pursuant to this Petition. 

Significantly, as set forth below, the technical specifications of the DJI Inspire 1, the DJI Inspire 1 operating documents, and HiFlite Productions LLC’s proposed operating limitations, 

ensure that HiFlite Productions LLC will safely operate the battery powered DJI Inspire 1 during daylight hours in visual meteorological conditions (VMC), under visual flight rules (VFR), 

with enough battery power to fly for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 4.5 minutes. 

5. Extent Of Relief HiFlite Productions LLC Seeks And The Reason HiFlite Productions 

LLC Seeks Relief From Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), And 

91.417(a) & (b). 

Since Sections 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) only apply 

to aircraft with an airworthiness certificate, Narrate Studios LLC requests relief from these Sections because the DJI Inspire 1 does not require airworthiness certificates. As set forth more 

fully below, the DJI Inspire 1 meets the conditions of FMRA Section 333 for operation without 

an airworthiness certificate. Accordingly, HiFlite Productions LLC will use trained technicians 

to perform maintenance, alterations, or preventive maintenance on the UASs using the methods, techniques, and practices prescribed in the UAS operating documents (i.e., the HiFlite 

Productions LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual).
D. The Reasons Why Granting HiFlite Productions LLC Request Would Be In The Public 

Interest; That Is, How It Would Benefit The Public As A Whole. 

Granting the present Petition will further the public interest by allowing HiFlite Productions 

LLC to safely, efficiently, and economically perform aerial video and photography of special 

events, film sets, and landscape over certain areas of the United States. 

Additionally, use of the DJI Inspire 1 will decrease congestion of the NAS, reduce pollution, 

and provide significant benefits to the economy. Notably, the benefits of HiFlite Productions 

LLC’s proposed operation of the DJI Inspire 1US will be realized without implicating any privacy issues. 

1. The Public Will Benefit From Decreased Congestion Of The NAS. 

The DJI Inspire 1 are battery powered and serve as a safe, efficient, and economical alternative 

to the manned aircraft traditionally utilized to obtain aerial imagery. By reducing the amount of 

manned aircraft needed to perform aerial acquisitions, an exemption allowing the use of a DJI 

Inspire 1 would reduce the amount of manned aircraft in the NAS, reduce noise and air pollution, as well as increase the safety of life and property in the air and on the ground. 

Furthermore, by reducing the number of manned aircraft operating in the NAS, congestion 

around airports caused by arriving and departing aircraft will be reduced. The DJI Inspire 1 do 

not require an airport to takeoff or land. Likewise, a reduction of manned aircraft conducting 

aerial video and photography missions would result in fewer aircraft that must be handled by 

air traffic control during the ground, takeoff, departure, arrival, and landing phases of flight operations. 

2. The Public Will Benefit From The Safety And Efficiency Of The DJI Inspire 1. 

Conducting aerial acquisitions with the DJI Inspire 1, instead of manned aircraft, will greatly 

benefit the public by drastically reducing the levels of air and noise pollution generated during 

traditional aerial video and still photography flight operations. By using battery power and 

electric motors, the DJI Inspire 1 produce no air pollution, and is the most viable environmentally conscious alternative to the cabin class, six cylinder internal combustion engine aircraft 

that are typically utilized for aerial video and photography, while burning approximately 20-30 

gallons per hour of leaded aviation fuel. The DJI Inspire 1, while reducing the carbon footprint 

of aerial acquisitions, also eliminates noise pollution, as the UAS are propelled by battery powered electric motors, rather than an internal combustion engine. 
By using the DJI Inspire 1 to perform aerial acquisitions, the substantial risk to life and property in the air and on the ground, which is usually associated with traditional manned aircraft 

flight operations, will be substantially reduced or completely eliminated. Aside from the lack of 

flight crew members located onboard the aircraft, the DJI Inspire 1 (weighing approximately 2 

pounds has less physical potential for collateral damage to life and property on the ground, and 

in the air, compared to the manned aircraft that typically conduct similar operations (weighing 

approximately 6,000 pounds with a wingspan of approximately 42 feet, a length of 34 feet, and 

a fuel capacity of 180 gallons). 

3. Performing Aerial Video and Photography Operations With The DJI Inspire 1 Will 

Benefit The Economy. 

In addition to being safe and efficient, the DJI Inspire 1 is also an economical alternative to using manned aircraft to conduct similar aerial operations. As such, operation of the DJI Inspire 1 

will allow United States based companies, like HiFlite Productions LLC, to remain competitive 

and contribute to growth of the U.S. economy. Specifically, with the rising cost of aviation fuel 

and the Environmental Protection Agency (“EPA”) regulatory actions phasing out leaded aviation fuels, U.S. owned and operated companies must adopt new and alternative technology in 

order to remain competitive. Operating the battery powered DJI Inspire 1 is one such technology that not only allows companies greater operational flexibility compared to manned aircraft, 

but provides such flexibility without the high operational cost of a traditional manned aircraft. 

By operating the DJI Inspire 1, companies such as HiFlite Productions LLC, can remain competitive and profitable, and therefore, provide greater job stability to employees and contractors, which will ultimately contribute to growth of the U.S. economy. Improved financial performance of U.S. companies, through commercial use of the DJI Inspire 1, provides a stable 

workforce that increases consumer spending; improves local, state, and federal tax revenues; 

and allows companies to invest in research and development in order to remain competitive 

both in the United States and abroad. 

4. There Are No Privacy Issues. 

Similar to the manned aerial acquisition flight operations that have been conducted for decades, 

HiFlite Productions LLC proposed operation of the DJI Inspire 1 will not implicate any privacy 

issues. Specifically, the DJI Inspire 1 will be operated only in compliance with operating documents (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Maintenance 

Log, and DJI Inspire 1 Instruction Manual) which requires property owner involvement as well 

as local law enforcement notification, and in accordance with the Federal Aviation Regulations, 

including the minimum altitude requirements of 14 C.F.R. § 91.119. 
E. The Reasons Why Granting The Exemption Would Not Adversely Affect Safety, Or 

How The Exemption Would Provide A Level Of Safety At Least Equal To That Provided 

By The Rule From Which HiFlite Productions LLC Seeks Exemption. 

1. Reasons Why The DJI Inspire 1 Meet The Conditions Of The FAA Modernization and 

Reform Act of 2012 (FMRA) Section 333. 

In consideration of the size, weight, speed, and limited operating area associated with the unmanned aircraft and its operation, HiFlite Productions LLC operation of the DJI Inspire 1 meet 

the conditions of FMRA Section 333, and will not require an airworthiness certificate in accordance with 14 C.F.R. Part 21, Subpart H. 

Section 333 provides authority for a UAS to operate without airworthiness certification and sets 

forth requirements for considering whether a UAS will create a hazard to users of the NAS or 

the public, or otherwise pose a threat to national security. Specifically, FMRA Section 333 

states the following, in part: 

(a) In General.--Notwithstanding any other requirement of this subtitle, and not later than 180 

days after the date of enactment of this Act, the Secretary of Transportation shall determine if 

certain unmanned aircraft systems may operate safely in the national airspace system before 

completion of the plan and rulemaking required by section 332 of this Act or the guidance required by section 334 of this Act. 

(b) Assessment of Unmanned Aircraft Systems.--In making the determination under subsection 

(a), the Secretary shall determine, at a minimum-- 

(1) which types of unmanned aircraft systems, if any, as a result of their size, weight, speed, operational capability, proximity to airports and populated areas, and operation within visual 

line of sight do not create a hazard to users of the national airspace system or the public or 

pose a threat to national security; and 

(2) whether a certificate of waiver, certificate of authorization, or airworthiness certification 

under section 44704 of title 49, United States Code, is required for the operation of unmanned 

aircraft systems identified under paragraph (1). 

(c) Requirements for Safe Operation.--If the Secretary determines under this section that certain unmanned aircraft systems may operate safely in the national airspace system, the Secretary shall establish requirements for the safe operation of such aircraft systems in the national 

airspace system. 
In seeking this exemption, HiFlite Productions LLC submits that the DJI Inspire 1 can operate 

safely in the NAS pursuant to FMRA Section 333, as demonstrated by: (a) the characteristics of 

the DJI Inspire 1; (b) the pilot certification requirement; and (c) the specific operating limitations. 

a. The Specifications Of The DJI Inspire 1 Demonstrate Its Safe Characteristics. 

The DJI Inspire 1 does not create a hazard to users of the NAS or the public, or otherwise pose 

a threat to national security considering its size, weight, speed, and operational capability. 

i. Technical Specifications Of The DJI Inspire 1. 

The technical specifications of the DJI Inspire 1 is set forth by the DJI Inspire 1 Specifications 

and Data Sheet, attached hereto as Exhibit A. 

ii. The DJI Inspire 1 Autonomous Flight And Navigation Modes Enable The UAS To Remain Within A Defined Operational Area. 

The DJI Inspire 1 may be operated in both manual and fully autonomous flight modes. A complete description of the flight and navigational modes of the DJI Inspire 1 is provided at pages 

25-35 of the DJI Inspire 1User Manual, attached hereto as Exhibit B. 

iii. The DJI Inspire 1 Are Designed For Automatic Return To Home Point Or Hover In 

The Event Of Loss Of The Control Link Or Navigation. 

When the Control Link is lost, the DJI Inspire 1 will remain stationary, in flight, for 3 seconds 

or more. If, after 3 seconds, the DJI Inspire 1 does not reacquire control link data from the 

GCS, the UA will assume that the Control Link is lost and the UA will return to the home position (i.e., failsafe mode) via GPS, and will descend to the takeoff position and shutdown. 

A complete description of the Failsafe Functions of the DJI Inspire 1 are set forth at pages 27 

through 29 of the DJI Inspire 1User Manual, attached here to as B. 
iv. The DJI Inspire 1GCS And Its Operation. 

A complete description of the operation and specifications of the DJI Inspire 1GCS and flight 

control software is provided at pages 32 through 43 of the DJI Inspire 1User Manual. DJI Inspire 1User Manual is attached hereto as Exhibit B. 

b. Flight Operations Of DJI Inspire 1 Are Limited To The Line Of Sight Of A Certificated 

Pilot in Command With A Safety Observer. 

HiFlite Productions LLC will only utilize certificated pilots who possess a current and valid 

airman medical certificate to act as a pilot in command (PIC) of the DJI Inspire 1. Additionally, 

a safety observer will assist all pilots during flight time. 

c. Flights Of DJI Inspire 1 Will Be Conducted Pursuant To Specific Operating Limitations. 

In seeking this exemption, proposes to commercially operate DJI Inspire 1 for the special purpose of conducting aerial video and photography over certain areas of United States, pursuant 

to the following specific operating limitations: 

1. Operations authorized by this grant of exemption will be limited to the following aircraft described in the operating documents, rotorcraft UASs weighing less than 55 pounds maximum 

gross weight: DJI Inspire 1Unmanned Aircraft. Proposed operations of any other aircraft will 

require a new petition or a petition to amend this grant. 

2. UAS operations under this exemption will be limited to conducting operations for the purpose of aerial video and photography. 

3. The UAS may not be flown at an indicated airspeed exceeding 20 knots. 

4. The UAS must be operated at an altitude of no more than 500 feet above ground level 

(AGL), as indicated by the procedures specified in the operating documents unless a special 

request is made and approved by ATC. All altitudes reported to ATC must be in feet AGL. 

5. The UAS must be operated within visual line of sight (VLOS) of the PIC at all times. This 

requires the PIC to be able to use human vision unaided by any device other than corrective 

lenses, as specified on the PIC’s FAA-issued airman medical certificate. 
6. The use of first person view (FPV) by the PIC or safety observer (SO) is not permitted. 

7. All operations must utilize a safety observer (SO). The SO may be used to satisfy the VLOS 

requirement as long as the PIC always maintains VLOS capability. The SO and PIC must be 

able to communicate verbally at all times. Electronic messaging or texting is not permitted during flight operations. The PIC must be designated before the flight and cannot transfer his or 

her designation for the duration of the flight. The PIC must ensure that the SO can perform the 

functions prescribed in the operating documents. 

8. The SO must not perform any other duties beyond assisting the PIC with seeing and avoiding 

other air traffic and other ground based obstacles/obstructions and is not permitted to operate 

the camera or other instruments. 

9. The operating documents and the grant of exemption must be accessible during UAS operations and made available to the Administrator upon request. If a discrepancy exists between the 

conditions and limitations contained in the grant of exemption and the procedures outlined in 

the operating documents, the conditions and limitations contained in the grant of exemption 

take precedence and must be followed. Otherwise, the operator must follow the procedures as 

outlined in its operating documents. The operator may update or revise its operating documents. It is the operator’s responsibility to track such revisions and present updated and revised 

documents to the Administrator upon request. The operator must also present updated and revised documents if it petitions for extension or amendment to the grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted the exemption, then the operator must petition for amendment to its grant of exemption.

10. Prior to each flight the PIC must inspect the UAS to ensure that it is in a condition for safe 

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the 

UAS is found to be in a condition for safe flight. The Ground Control Station must be included 

in the preflight inspection. All maintenance and alterations must be properly documented in the 

aircraft records. 

11. Any UAS that has undergone maintenance or alterations that affect the UAS operation 

or flight characteristics, e.g. replacement of a flight critical component, must undergo a 

functional test flight. The PIC who conducts the functional test flight must make an entry in the aircraft records. 

12. The pre-flight inspection must account for all potential discrepancies, e.g. inoperable 

components, items, or equipment, not already covered in the relevant sections of the operating documents. 
13. The operator must follow the UAS manufacturer’s aircraft/component, maintenance, 

overhaul, replacement, inspection, and life limit requirements. 

14. The operator must carry out its maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, alterations, and status of replacement/overhaul component parts must be noted in the aircraft 

records, including total time in service, description of work accomplished, and the signature of the authorized person returning the UAS to service. 

15. Each UASs operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

16. The authorized person must make an entry in the aircraft record of the corrective action 

taken against discrepancies discovered between inspections. 

17. The PIC must possess at least a private pilot certificate and at least a current third- class 

medical certificate. 

18. The operator may not permit any PIC to operate unless the PIC meets the operator’s 

qualification criteria and demonstrates the ability to safely operate the UAS in a manner 

consistent with how the UAS will be operated under the exemption, including evasive 

and emergency maneuvers and maintaining appropriate distances from persons, vessels, 

vehicles and structures. PIC qualification flight hours must be logged in a manner consistent with 14 C.F.R. § 61.51(b). Flights for the purposes of training the operator’s PICs 

are permitted under the terms of the exemption. However, training operations may only 

be conducted during dedicated training sessions. During training, proficiency, and experience-building flights, all persons not essential for flight operations are considered nonparticipants, and the PIC must operate the UA with appropriate distance from nonparticipants in accordance with 14 C.F.R. § 91.119. 

19. UAS operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All 

operations must be conducted under visual meteorological conditions (VMC). If flight at 

night is required, a special request will be made at the FAA office closest to proposed 

area of operations. Flights under special visual flight rules (SVFR) are not authorized. 
 20. The UA may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a 

NOTAM as required by the operator’s COA. The letter of agreement with the airport 

management must be made available to the Administrator upon request. 

 21. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC. 

 22. If the UA loses communications or loses its GPS signal, it must return to a pre- determined location within the planned operating area and land or be recovered in accordance 

with the operating documents. 

 23. The PIC must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the operating documents. 

 24. The PIC is prohibited from beginning a flight unless (considering wind and forecast 

weather conditions) there is enough power to fly at normal cruising speed to the intended landing point and land the UA with 25% battery power remaining. 

 25. The operator must obtain an Air Traffic Organization (ATO) issued Certificate of Waiver 

or Authorization (COA) prior to conducting any operations under the grant of exemption. This COA will also require the operator to request a Notice to Airman (NOTAM) 

not more than 72 hours in advance, but not less than 48 hours prior to the operation. All 

operations shall be conducted in accordance with airspace requirements in the ATO issued COA including class of airspace, altitude level and potential transponder requirements. 

 26. All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 C.F.R. part 47, and have identification (N- Number) markings in accordance with 14 C.F.R. part 45, Subpart C. Markings must be as 

large as practicable. 

27. Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or 

other appropriate government oversight agency requirements. 
 28. The documents required fewer than 14 C.F.R. 91.9 and 91.203 must be available to the 

PIC at the Ground Control Station of the UAS any time the UAS is operating. These 

documents must be made available to the Administrator or any law enforcement official 

upon request. 

 29. The UA must remain clear and yield the right of way to all manned aviation operations 

and activities at all times. 

 30. The UAS may not be operated by the PIC from any moving device or vehicle. 

 31. Flight operations must be conducted at least 500 feet from all nonparticipating persons 

(persons other than the PIC, SO, operator trainees or essential persons), vessels, vehicles, and structures unless: 

a. Barriers or structures are present that sufficiently protect nonparticipating persons 

from the UA and/or debris in the event of an accident. The operator must ensure that 

nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately and/or; 

b. The aircraft is operated near vessels, vehicles or structures where the owner/controller 

of such vessels, vehicles or structures has granted permission and the PIC has made a 

safety assessment of the risk of operating closer to those objects and determined that it 

does not present an undue hazard, and; 

c. Operations nearer to the PIC, SO, operator trainees or essential persons do not present 

an undue hazard to those persons per § 91.119(a). 

 32. All operations shall be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from 

land owner/controller or authorized representative will be obtained for each flight to be 

conducted. 

 33. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the 

FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents must be reported to 

the National Transportation Safety Board (NTSB) per instructions contained on the 

NTSB Web site: www.ntsb.gov. 
2. Reasons Why An Exemption From The Requirements Of Section 61.113(a) And (b) 

Would Not Adversely Affect Safety. 

HiFlite Productions LLC submits that the equivalent level of safety established by Section 

61.113(a) and (b) will be maintained because no PIC will be allowed to operate the DJI Inspire 

1 unless that PIC has demonstrated, by meeting minimum flight-hour and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a manner consistent with the 

exemption, including evasive and emergency maneuvers and maintaining appropriate distances 

from people, vessels, vehicles and structures. 

Considering HiFlite Productions LLC proposed area of operations, and the operating limitations set forth-above; the parallel nature of private pilot aeronautical knowledge requirements 

to those of commercial pilot requirements (See Exemption No. 11062); and the airmanship 

skills necessary to safely operate the DJI Inspire 1, HiFlite Productions LLC submits that the 

additional manned airmanship experience of a commercially certificated pilot would not correlate to the airmanship skills necessary for HiFlite Productions LLC specific proposed flight operations. 

The FAA has previously granted relief from Section 61.113(a) and (b) specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11158, 11159, 11160, 11161). 

HiFlite Productions LLC will not allow any PIC to operate the DJI Inspire 1 unless that PIC 

has demonstrated, by meeting minimum flight-hour requirements or the DJI Inspire 1 training 

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a manner 

consistent with this exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

Specifically, the PIC must have accumulated and logged, in a manner consistent with 14 C.F.R. 

§ 61.51(b), 25 hours of total time as a UAS rotorcraft pilot (with a minimum of 5 hours of 

those hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption). In addition to the hour requirements, the PIC must accomplish 3 

takeoffs and landings in the preceding 90 days (for currency purposes). 

As in Exemption Nos. 11062, 11138, and 11153, prior documented flight experience that was 

obtained in compliance with applicable regulations will ensure an equivalent level of safety 

during HiFlite Productions LLC proposed operations. The Administrator has held that prior 

documented flight experience that was obtained in compliance with applicable regulations 

would ensure safe operations, stating as follows: 
In Exemption No. 11062, the FAA required that prior to conducting operations for the purpose 

of motion picture filming (or similar operations), the PIC must have accumulated and logged, 

in a manner consistent with 14 CFR 61.51(b), 25 hours of total time as a UAS rotorcraft pilot 

including at least 10 hours logged as a UAS pilot with a multi-rotor UAS. Prior to operations 

under Exemption No. 11062, the PIC must also have accumulated and logged a minimum of 5 

hours as a UAS pilot operating the same make and model of UAS to be used for operations under the exemption. For clarification, the FAA considers these minimum hour requirements to be 

inclusive rather than additive; i.e. 5 hours make and model time may be included in the 10 

hours of multi-rotor time and the 10 hours may be included in the total 25 hours of UAS rotorcraft time. In addition to the hour requirements, the PIC must accomplish 3 takeoffs and landings in the preceding 90 days (for currency purposes). The FAA finds that at a minimum, the 

flight-hour requirements in Exemption No. 11062 are appropriate to practice and build proficiency in the skills necessary to safely conduct the petitioner’s proposed operations. The FAA 

also finds that prior documented flight experience that was obtained in compliance with applicable regulations would satisfy this requirement. Training, proficiency, and experience-building 

flights can also be conducted under the grant of exemption to accomplish the required flight 

time. During training, proficiency, and experience-building flights the PIC is required to operate the UA with appropriate distances in accordance with 14 C.F.R 91.119. 

Exemption No. 11138 at page 15.

Accordingly, HiFlite Productions LLC will ensure safe operations by not allowing any PIC to 

operate the DJI Inspire 1 unless that PIC has demonstrated, by meeting minimum flight-hour 

and currency requirements, that the PIC is able to safely operate the DJI Inspire 1 in a manner 

consistent with the exemption, including evasive and emergency maneuvers and maintaining 

appropriate distances from people, vessels, vehicles and structures. 

3. Reasons Why An Exemption From The Requirements Of Section 91.7(a) Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.7(a) will be maintained because prior 

to every flight, HiFlite Productions LLC will ensure that the DJI Inspire 1 is in an airworthy 

condition based upon the UAS’s compliance with its operating documents and as stated in the 

conditions and limitations herein. 

Additionally, the FAA has previously granted relief from Section 91.7(a) specific to UAS, in 

circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 

11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 11112, 11136, 11138, 11150, 

11153, 11156, 11157, 11158, 11159, 11160, 11161). 
4. Reasons Why An Exemption From The Requirements Of Section 91.121 Would Not 

Adversely Affect Safety. 

The equivalent level of safety established by Section 91.121 will be maintained because the altitude information of the DJI Inspire 1 will be provided to the PIC via GPS equipment and a 

radio communications telemetry data link, which downlinks from the UAS to the GCS for active monitoring of the flight path and altitude. This altitude information, combined with HiFlite 

Productions LLC’s operation of the DJI Inspire 1 within visual line of sight, at or below 500 

feet AGL, will ensure a level of safety equivalent to Section 91.121. The altitude information 

will be generated by GPS equipment installed onboard the aircraft. Prior to each flight, a zero 

altitude initiation point is automatically established by the UASs at ground level. 

The FAA has previously granted relief from Section 91.121 specific to UAS, in circumstances 

similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 

11064, 11065, 11066, 11067, 11080, 11109, 11112, 11136, 11138, 11150, 11153, 11156, 11157, 

11158, 11159, 11160, 11161). 

5. Reasons Why An Exemption From The Requirements Of Section 91.151(b) Would Not 

Adversely Affect Safety. 

A grant of this exemption would ensure an equivalent level of safety established by 14 C.F.R. 

Section 91.151(b) as a result of (1) the technical specifications of the DJI Inspire 1; (2) the limitations on the proposed flight operations; and (3) the location of the proposed flight operations. 

Accordingly, HiFlite Productions LLC will ensure that it will safely operate the battery powered DJI Inspire 1 during daylight hours in VFR conditions, with enough battery power to fly 

for a total duration of 13.5 minutes to the first point of intended landing and, assuming normal 

cruising speed, to fly after that for at least 4.5 minutes. 

Here, as in Exemption No. 11109, the technical specifications of the DJI Inspire 1; the limitations on the proposed flight operations; and the location of the proposed operations, will ensure 

an equivalent level of safety established by 14 C.F.R. Section 91.151(b). Furthermore, safety 

will be ensured as the DJI Inspire 1 provide audible and visual warnings to the PIC at the GCS 

when the UAS experiences low battery voltage, the first warning occurring at approximately 

33% remaining battery power, and again at approximately 10% remaining battery power. At the 

critically low battery level, the DJI Inspire 1 will descend and land automatically. 

Significantly, previous exemptions granted by the FAA concerning Section 91.151 establish 

that safety is not adversely affected when the technical characteristics and operating limitations 

of the UAS are considered. Relief has been granted for manned aircraft to operate at less than 

the minimums prescribed in Section 91.151, including 
Exemption Nos. 2689, 5745, and 10650. Moreover, the FAA has previously granted relief from 

Section 91.151 specific to UAS, in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 8811, 10808, 10673, 11042, 11062, 11063, 11064, 11065, 

11066, 11067, 11080, 11109, 11110, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 

11160, 11161). 

6. Reasons Why An Exemption From The Requirements Of Sections 91.405(a), 91.407(a)

(1), 91.409(a)(1) & (a)(2), And 91.417(a) & (b) Would Not Adversely Affect Safety. 

In seeking this exemption, HiFlite Productions LLC submits that the equivalent level of safety 

with regard to the regulatory maintenance and alteration requirements established by Sections 

91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) will be met because HiFlite 

Productions LLC will use trained technicians to perform maintenance, alterations, or preventive 

maintenance on the UAS using the methods, techniques, and practices prescribed in the operating documents (i.e., the HiFlite Productions LLC Aerial Operations Manual, Monthly Maintenance Log, and DJI Inspire 1 Instruction Manual). Furthermore, HiFlite Productions LLC will 

document and maintain all maintenance records for the DJI Inspire 1. 

Since the DJI Inspire 1 will be inspected as prescribed by the operating documents, HiFlite 

Productions LLC will maintain the equivalent level of safety established by Sections 91.405(a), 

91.409(a)(1), and 91.409(a)(2). A copy of the DJI Inspire 1User Manuals are attached hereto as 

Exhibit B; a copy of the DJI Inspire 1 Maintenance LOG is attached hereto as Exhibit C. 

Likewise, the exemption sought will not adversely affect safety because HiFlite Productions 

LLC will use trained technicians to perform maintenance, alterations or preventive maintenance on the UAS using the methods, techniques, and practices prescribed by the operating 

documents. 

Furthermore, the exemption sought would maintain an equivalent level of safety established by 

Sections 91.407, 91.417(a) and 91.417(b), because all maintenance of the DJI Inspire 1 will be 

performed by trained technicians. Maintenance will be documented and maintained utilizing 

the monthly maintenance log. 

Significantly, previous exemptions granted by the FAA concerning Sections 91.405(a), 

91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b) establish that safety is not adversely 

affected when the technical characteristics and operating limitations of the UAS are considered. 

In consideration of HiFlite Productions LLC proposed operating limitations, the operating documents, and the technical aspects of the DJI Inspire 1, HiFlite Productions LLC submits that 

safety will not be adversely affected by granting exemption from 14 C.F.R. Sections 91.405(a), 
91.407(a)(1) and (a)(2), 91.409(a)(2), and 91.417(a) and (b). The FAA has previously granted 

relief specific to UAS in circumstances similar, in all material respects, to those presented herein (e.g. Exemption Nos. 11062, 11063, 11064, 11065, 11066, 11067, 11080, 11109, 11110, 

11112, 11136, 11138, 11150, 11153, 11156, 11157, 11158, 11159, 11160, 11161). 

7. The FAA May Prescribe Any Other Conditions For Safe Operation. 

In accordance with Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA) 

and 14 C.F.R. § 21.16 entitled Special Conditions, HiFlite Productions LLC requests that the 

FAA prescribe special conditions for the intended operation of the DJI Inspire 1, which contain 

such safety standards that the Administrator finds necessary to establish a level of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R §§ 61.113(a) & (b), 91.7 

(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 91.417(a) & (b). 

Such special conditions will permit safe operation of the UA for the limited purpose of conducting aerial video and photography over certain areas of the United States for compensation 

or hire. FMRA Section 333 sets forth the requirements for considering whether a UAS will create a hazard to users of the NAS or the public, or otherwise pose a threat to national security; 

and further, provides the authority for such UAS to operate without airworthiness certification 

in accordance with any requirements that must be established for the safe operation of the UAS 

in the NAS. 

Likewise, the Administrator may prescribe special conditions pursuant to 14 C.F.R. § 21.16, for 

operation of the DJI Inspire 1, since the airworthiness regulations of 14 C.F.R. Part 21 do not 

contain adequate or appropriate safety standards, due to the novel or unusual design features of 

the aircraft. Section 21.16, entitled Special Conditions, states the following: 

If the FAA finds that the airworthiness regulations of this subchapter do not contain adequate or 

appropriate safety standards for an aircraft, aircraft engine, or propeller because of a novel or 

unusual design feature of the aircraft, aircraft engine or propeller, he prescribes special conditions and amendments thereto for the product. The special conditions are issued in accordance 

with Part 11 of this chapter and contain such safety standards for the aircraft, aircraft engine or 

propeller as the FAA finds necessary to establish a level of safety equivalent to that established 

in the regulations. 

See 14 C.F.R. § 21.16.

Therefore, in accordance with FMRA Section 333 and 14 C.F.R. § 21.16, the FAA 

may prescribe special conditions for Leading Edge’s intended operation of the DJI Inspire 1, 

which contain such safety standards that the Administrator finds necessary to establish a level 

of safety equivalent to that established by 14 C.F.R. Part 21, Subpart H, and 14 C.F.R Sections 

61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 
F. A Summary That Can Be Published In The Federal Register, stating: The Rules From 

Which HiFlite Productions LLC Seeks Exemption: 

HiFlite Productions LLC seeks exemption from the requirements of 14 C.F.R Sections 

61.113(a)&(b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)(2), and 

91.417(a) & (b). 

A Brief Description Of The Nature Of The Exemption HiFlite Productions LLC Seeks: 

This exemption will permit HiFlite Productions LLC to commercially operate an Unmanned 

Aircraft System (UAS) for the purpose of conducting aerial video and photography over certain 

areas of the United States. 

G. Any Additional Information, Views, Or Arguments Available To Support HiFlite Productions LLC Request. 

This Petition is made pursuant to the FAA Modernization and Reform Act of 2012 (FMRA) 

Section 333, which directs the Secretary of Transportation to determine if certain UAS may operate safely in the NAS. As such, HiFlite Productions LLC request for exemption may be 

granted pursuant to the authority of FMRA Section 333 and 14 C.F.R. Part 11, as set forth 

above. 

FMRA Section 333 sets forth the requirements for considering whether a UAS will create a 

hazard to users of the NAS or the public, or otherwise pose a threat to national security; and 

further, provides the authority for such UAS to operate without airworthiness certification. 

As discussed in detail above, HiFlite Productions LLC will operate the DJI Inspire 1 safely in 

the NAS, without creating a hazard to users of the NAS, or the public, or otherwise pose a 

threat to national security. 
CONCLUSION 

As set forth herein, HiFlite Productions LLC seeks an exemption pursuant to 14 C.F.R. § 11.61 

and Section 333 of the FAA Modernization and Reform Act of 2012 (FMRA), which will permit safe operation of the DJI Inspire 1 commercially, without an airworthiness certificate, for 

the limited purpose of conducting aerial video and photography over certain areas of the United 

States. By granting this Petition, the FAA Administrator will be fulfilling the Congressional 

mandate of the FAA Modernization and Reform Act of 2012, while also advancing the interests 

of the public, by allowing HiFlite Productions LLC to safely, efficiently, and economically operate the DJI Inspire 1 commercially within the NAS. 

WHEREFORE, in accordance with the Federal Aviation Regulations and the FAA Modernization and Reform Act of 2012, Section 333, HiFlite Productions LLC respectfully requests that 

the Administrator grant this Petition for an exemption from the requirements of 14 C.F.R Sections 61.113(a) & (b), 91.7(a), 91.121, 91.151(b), 91.405(a), 91.407(a)(1), 91.409(a)(1) & (a)

(2), and 91.417(a) & (b), and permit Leading Edge to operate the DJI Inspire 1 commercially 

for the purpose of conducting aerial video and photography over certain areas of the United 

States. 

Dated: August 11, 2015 

Respectfully submitted, Ethan Gulnac

Ethan Gulnac

HiFlite Productions LLC

2385 Puu Mala Place Kihei, HI 96753

Tel: (808) 874-3512

Email: hifliteproductions@gmail.com